OSHA Rules Relating to Grain Facilities
By: Gardiner Thomsen CPAs | email
In August, all grain facility storage operators should have received a letter from OSHA addressing recent accidents in grain elevators, rules to comply with when entering bins and recent penalties assessed for hazard violations. The letter reminded all employers in the grain industry that they must comply with the rules in OSHA’s Grain Handling Facilities standard, 29 CFR 1910.272.
The letter listed very specific responsibilities of the employers when their workers enter storage bins.
Obviously we have a concern for the safety of all our clients, sympathies for any work-related deaths and concerns over financial penalties assessed. You might wonder why we are addressing this issue. Remember, we observe your inventories as a function of the audit process. And, in most cases, enter grain storage bins.
As you know, your Gardiner Thomsen auditors take grain measuring very seriously. We have never taken the position or purported to our clients that we are only “measuring to ensure adequacy of what the DPR calls for stored grain”. Historically, when we measured your grain, we were confident with our measurements. We would compare our measurements to recent examiner measurements, our prior year measurements and in some cases, our client’s measurements.
We will need to read these rules ourselves and then consult with you and comply with your bin entry procedures as we do your grain measuring in the future. Although we don’t have the answers today, it will change what we have done in the past.
What are we considering?
- Outsourcing our grain measuring to others “qualified” for confined-space entry.
- Not entering grain storage bins.
- Relying on examiner’s measurements if within an acceptable time period.
- Relying on your internal measurements.
We will be addressing this in the coming months and are likely to speak to a number of you for your feedback and expectations. In the meantime, have a safe harvest!
